This document is made available by the Securities Industry Association. It is a very simplified outline. Note the deadline for beginning: Jan. 1996. Note also the requirement of parallel testing, which requires simultaneous entry of data to the original system and the repaired one. This must begin no later than September 1997. Yet this requires a complete parallel mainframe computing system. This means that the present system is running at less than 50% capacity. Yet almost no organization has this much spare mainframe capacity in reserve. And not every old IBM mainframe can be replaced. It gtakes over a year to get delivery today. What if there were tens of thousands of orders?

My conclusion: parallel testing will not be done. The world will fly blind with whatever repairs it has made as of Jan. 1, 2000. My next conclusion: the world will crash.